Ralph M. and Rosemary L. Conlon - Page 5

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          1994, Mr. Mark telephoned to request audit reconsideration.                 
          During a second telephone conversation on November 18, 1994, Mr.            
          Mark indicated that he would be providing additional information            
          to counter respondent’s deficiency determination.  At that time,            
          respondent’s agent informed Mr. Mark that the last day to file a            
          petition with the Court was November 24, 1994.2                             
               Neither petitioners nor Mr. Mark contested respondent’s                
          determinations in the notice of deficiency by filing a petition             
          with this Court.                                                            
               On March 6, 1995, respondent assessed against petitioners              
          the deficiency and penalty determined in the notice of                      
          deficiency, together with statutory interest, and thereafter                
          began collection proceedings against petitioners.                           
               On November 1, 2001, respondent issued to petitioners a                
          Final Notice of Intent to Levy and Notice of Your Right to a                
          Hearing (notice of intent to levy), pursuant to sections 6330(a)            
          and 6331(d)(2), pertaining to petitioners’ outstanding liability            
          for 1991.                                                                   
               On November 5, 2001, petitioners submitted a Form 656, Offer           
          in Compromise, to respondent.  Petitioners did not check any of             
          the boxes under the reason for submission of the offer–-doubt as            
          to liability, doubt as to collectibility, or effective tax                  

               2  Nov. 24, 1994, was Thanksgiving Day; accordingly, the               
          last day was Nov. 25, 1994.  See sec. 7503.                                 

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